EXHIBIT 16.1

Disclosure of Mine Safety and Health
Administration (MSHA) Safety Data

MFC Industrial Ltd.'s Pea Ridge Mine in
the United States is subject to regulation by MSHA under the United States
Federal Mine Safety and Health Act of 1977 (the "Mine Act"). MSHA inspects mines
and issues various citations and orders when it believes a violation has
occurred under the Mine Act, and it typically proposes a civil penalty, or fine,
related to the alleged violation.

The following disclosures are provided
pursuant to Section 1503(a) of theDodd-Frank
Wall Street Reform and Consumer Protection Act(Dodd-Frank), which requires certain disclosures by companies
operating mines regulated under the Mine Act and which are required to file
periodic reports under theSecurities Exchange
Act of 1934.

During the year ended December 31,
2012, the Pea Ridge Mine did not receive a written notice from MSHA of (a) a
pattern of violations of mandatory health or safety standards that are of such
nature as could have significantly and substantially contributed to the cause
and effect of mine health or safety hazards under section 104(e) of the Mine Act
or (b) the potential to have such a pattern.

The information in the table below
reflects citations and orders issued by MSHA inspectors to the relevant Pea
Ridge Mine site during the year ended December 31, 2012. This data may not match
or reconcile with the data MSHA maintains on its public website.

In evaluating this information,
consideration should be given to factors such as: (a) the number of citations
and orders may vary depending on the size, nature of operations and operational
status of the mine, (b) the number of citations issued may vary from inspector
to inspector and mine to mine, and (c) citations and orders may be contested and
appealed, a process which may result in a reduction in severity and amount, or
they might be dismissed.

Mine Safety Disclosures

|Mine Act Section 104 
      Significant and Substantial Citations                                   |   | 1     | 
|---------------------------------------------------------------------------------------------------- | - | ----- | 
|Mine Act Section 104(b) Orders                                                                       |   | -     | 
|Mine Act Section 104(d)
      Citations and Orders                                                   |   | 1     | 
|Mine Act Section 110(b)(2) Flagrant
      Violations                                                 |   | -     | 
|Mine Act Section 107(a)
      Imminent Danger Orders                                                 |   | -     | 
|Total US$ Value of Proposed MSHA
      Assessments                                                   | $ | 2,300 | 
|Total Number of Mining
      Related Fatalities                                                      |   | -     | 
|Received Notice of Pattern of Violations
      Under Mine Act Section 104(e)                         |   | No    | 
|Received Notice of
      Potential to Have Pattern of Violations Under Mine Act Section
      104(e) |   | No    | 
|Total number of pending legal actions before
      the Federal Mine Safety and Health Review         |   | -     | 
|Commission
      (FMSHRC)                                                                          |   |       | 
|Number of pending contests of citations and
      orders                                             |   | -     | 
|Number of pending contests
      of proposed penalties                                               |   | -     | 
|Number of pending complaints for
      compensation                                                  |   | -     | 
|Number of pending
      complaints of discharge                                                      |   | -     | 
|Number of pending applications for temporary
      relief                                            |   | -     | 
|Number of pending appeals
      of judges decisions or orders to the FMSHRC                         |   | -     | 
|Total number of legal actions instituted by
      the FMSHRC                                         |   | -     | 
|Total number of legal
      actions before the FMSHRC resolved                                       |   | -     | 

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